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Home My WebLink About08-4454a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), N Plaintiff No: 03- 4q S5 0-Avi1 IerM VS. COMPLAINT IN CIVIL ACTION ALISHA A BOYER AKA ALISHA BOYER Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06741911 C N Pit IAS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), N h Plaintiff VS. Civil Action No ALISHA A BOYER AKA ALISHA BOYER Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, CAPITAL ONE BANK (USA), N h is a corporation with offices at 15000 CAPITAL ONE DRIVE RICHMOND , VA 23238 . 2. Defendant is adult individual(s) residing at the address listed below: ALISHA A BOYER 88 TIPTOP CIR CARLISLE, PA 17015 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXXXXXX9910 . 4. Defendant made use of said credit card and has a current balance due of $1136.61 , as of June 06, 2008 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 16.600% per annum on the unpaid balance from June 06, 2008 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit 11111 and made a part hereof. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant , ALISHA A BOYER , INDIVIDUALLY , in the amount of $1136.61 with continuing interest thereon at the rate of 16.600% per annum from June 06, 2008 plus costs. James 91 . nE-V1bBE.. rodt,42524 WELT , & REIS CO., L.P.A. 436 venth Avenue, Suite 1400 Pitt trgh, PA 15219 (41 ) 434- 955 FAX. 41?- 38-7130 06 4191 C N Pit IAS This law firm is a debt collector atteng to collect this debt for our client and any information obtaine ill be used for that purpose. FINANCE Previous Balance Payments & Credits CHARGE Transactions New Balance Minimum Payment Due Date $854 82 - $0 00 + $11 87 + $78 00 = $944 69 $155 00 Oct 30, 2007 Sep 06, 2007 -Oct 05, 2007 Page 1 of 2 .•. PLEASE PAY AT (FAST TIC AMMAT Visa Platinum Account Your account is six payments behind If we charge off your account due to late payments, we rill report the 4862 3624883&9910 Q/?oHaf * charged-off status to several national credit bureaus, and the Purchase APR as reflected on this statement will be applied to all your ouistandn balances A t t . g now c o prevent the from happening Please pay the amount due Your Account Information REWARDS on your stalemer t or give us a call at 1 $00 955,6600 Well work with you so you can take control of your TOTAL CREDIT LINE $80000 account and start rebuilding your credit who Capital One TOTAL AVAILABLE CREDIT $000 CREDIT LINE FOR CASH $800 00 -important Notice" Under the terms we 9 previously disclosed to you, your account is now of able for an increase AVAILABLE CREDIT FOR CASH $000 in Annual Percentage Rates (APRs) effect" immediately However, Capital One has elected not to raise your APRs at this lime Please be advised that d you fal to keep your account n good standing, Capital One reserves the right to raise your APRs in the future Finance Charges (Please see reverse for important information) Balance rate Periodic Corresponding FINALE l d t Rewards Summary app ie o rate APR CHARGE Previous available balance 413 Purchases $867 00 0 04562% P 1665% $1187 Famed the period 0 Cash $0 90 0 06452% P 2355% $000 (reteols transactions posted during ors bang cycle) ANNUAL PERCENTAGE RATE applied this period. 16.85% Available Balance 413 Q At Your service 1.8to.955.7070 Payments, Credits & Adlustments To cal Customer Relations or ho report a bat or stolen card ® Send paymerdsto. Transactions Capital One BariP 0 Bra 70884 Charbos, NC 28272MM 1 01 OCT PAST DUE FEE $3900 2 05 OCT OVERLIMIT FEE OCT 05,2D07 $3900 A Send inquiries to. Capital One P 0 Brno 30285 Sea Lake City, UT 8413D-0285 AN& For more information on your Rewards. 1rst: wwwwp"ifeloneimuUokbrewede ® Call ,$W-228300, EXH ® Have a quest in about a charge on your stat ment7 IBff Please refer to the Bdung Rights Summary on the back of your statement orwsd www caodalone comldisoutes. 6056 506 1 07 5 071005 PAGE 1 of 2 OIDM6056 PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO W WW CAPITALONE COM TO MAID YOUR PAYMENT ONLINE capita ()w I what's in your walleW New Balance Minimum Payment Due Date C$944 69 $155 00 Oct 30, 2007 PLEASE PAY AT LEAST THIS AMOUNT 4862362488389910 05 0944690200000155008 Amount Enclosed Capital One Bank P.O. Box 70664 Charlotte, NC 28272-0664 Account Number. 4862-3624-8838-9910 Please print address or phone number changes below using blue or black ink Address Hone Phone Alternate Phone E-cocci address CI #90279759366867760 MAIL ID NUMBER ALISHA A BOYER 66 TIPTOP CIR CARLISLE, PA 17D15-7741 ulI I I I I I I I I Inn II I II II II nrI I nlI II uIIII11lrr1I111 11111 6741911 Please write your account number on your check or money order made payable to Capital One Bank and mall with this coupon in the enclosed envelope VERIFICATION CAPITAL ONE BANK (USA), N.A. vs BOYER, ALISHA A The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities, that he/she is, TRACY TAYLOR, Authorized Agent, of CAPITAL ONE BANK (USA), N.A., Plaintiff Herein, that he/she is duly authorized to make this Declaration, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. TRACY TAYLOR Notary Public ARYOrNNE MABSON+ NOTARY PUBL!C V'tCJCALfs COUNTY, GEOR:, !k iv + %: IM iSION EXPIRF> :011 4862362488389910 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. ' `i * od 17 , `= (11 17- ?.._ r.?M =J CD `. _` c'a SHERIFF'S RETURN - REGULAR CASE NO: 2008-04454 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK USA N A VS BOYER ALISHA A ET AL KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE BOYER ALISHA A AKA ALISHA BOYER was served upon the DEFENDANT , at 0017:02 HOURS, on the 29th day of July , 2008 at 88 TIP TOP CIRCLE CARLISLE, PA 17015 MT T (ITTT T7l1V11D DEFENDANT by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 510110 r C?, ? Sworn and Subscibed to before me this of So Answers: 18.00 7.00 .00 10.00 R. Thomas Kline .00 35.00 07/30/2008 WELTMAN WEINBERG & REIS By. /? I day De uty She r , A.D. 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), N.A. Plaintiff vs. No. 08-4454- CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITH PREJUDICE ALISHA A BOYER Defendants FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6741911 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), N.A. Plaintiff vs. Civil Action No. 08-4454- CIVIL TERM ALISHA A BOYER Defendants PRAECIPE TO SETTLE DISCONTINUE AND END WITH PREDJUDICE TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue the above captioned matter upon the records of the Court with prejudice and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczan, Es ire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#6741911 Sworn to and subscribed Before me the 23RD Da o EBRUARY 009 N RY 41C TH OF PENNSYLVANW NotrW Seel Jwnger M. Borowski, Notary PWft Cky of PNbburgh, Aft9hory County ConvNe n EVtft Feb. 22, 2012 Mernber, Panneyk" A980010 M of Notaries C7 "a rlo { c:>